Comprehensive Environmental Performance Inspection

DOE&CD-E&OHU-CEPI-001
DOE&CD-E&OHU-CEPI-001-R0_CEPI Date: January 2013
Document Title: Comprehensive Environmental Performance Inspection
Document Owner: Division Head / DOE&CD
Review Interval: 48 Months

Contents Page

1. Purpose 2

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2. Scope 2
3. Objectives 2

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4. Definitions/Acronyms 2

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5. Procedure 3
6. Responsibilities 6
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Revision Summary 7
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DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
Revision(s) identified by a Vertical Bar in the Right Margin Page 1 of 7
This is an "UNCONTROLLED COPY" printed for reference only
 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
1. Purpose

The purpose of this procedure is to specify the minimum requirements for planning, performing,
documenting, and following up periodic internal Comprehensive Environmental Performance Inspection
(CEPI) of Drilling and Workover (D&WO) facilities.

2. Scope

This procedure applies to Environment and Occupational Health Unit (E&OHU) personnel involved in
conducting CEPI’s as directed by the E&OHU Supervisor.

3. Objective(s)

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A. Assess D&WO facilities level of compliance with environmental and health performance standards.

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B. Identify and evaluate existing and potential environmental and health hazards and significant
noncompliance issues in facilities.
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C. Ensure identified areas of non-compliance from previous CEPI’s have been properly resolved.
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D. Provide a comprehensive report to the proponent department on conditions related to environment

and health at its facilities.
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E. Increase the environmental awareness and performance of D&WO and rig contractor facilities,
thereby improving performance in EPD inspections.
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4. Definitions/Acronyms
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A. CEHA: Comprehensive Environmental Health Assessment.

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B. CEPI: Comprehensive Environmental Performance Inspection.

C. DOE&CD: Drilling operation Excellence & Compliance Division.

D. D&WO: Drilling and Workover.

E. EC: Environmental Coordinator.

F. EPA: Environmental Performance Assessment.

G. EPD: Environmental Protection Department.

H. E&OHU: Environmental and Occupational Health Unit.

I. Facility: Any fixed or mobile facility that belongs to D&WO or Rig Contractor.

DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
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 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
CEPI-001 / Continued

J. Non-Compliance: A deficiency or lack of compliance with any Saudi Aramco standard, code or
regulation.

K. OHHA: Occupational Health Hazard Assessment.

L. RPA: Radiation Protection Assessment.

5. Procedure

The inspection process is described in the following steps:

A. Facility Selection

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Facilities will be selected for CEPIs based on the following priorities:

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1) If there is an immediate identified threat to the environment or occupational health issue that has

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been presented to the E&OHU Supervisor.
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2) If there is an upcoming EPD audit (e.g. EPA, CEHA, RPA or OHHA) and the facilities belong to or
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are under contract to the D&WO department that is being audited.
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3) The remaining D&WO facilities not visited as a result of No.1 or No.2 above, will be visited a
minimum of once each year.
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B. Inspection Notification
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E&OHU will send a notification e-mail through the HSE automated inspection system to the
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superintendent of the facility to be inspected, and include the rig foreman the primary/backup EC’s for
the department, to arrange a convenient date and time.
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C. CEPI Team

CEPI team shall consist of at least one representative from DOE&CD. The EC for the department
being inspected is recommended to be part of the team, but this is not a requirement.

D. Inspection Preparation

1) Documents: Previous inspection reports, if available, shall be reviewed prior to the visit and
required corrective actions highlighted. Copies of empty check lists to be used during the
inspection process should be printed. Applicable references shall be available during the
inspection in order to clarify any questions raised.

2) Remote Area Travel: E&OHU will follow G.I.6.025 regarding requirements for remote area travel.
These minimum requirements include a sign-out/sign-in log system, adequate initial and refresher
training, a listing of the appropriate emergency procedures, and supplies and equipment that
should be carried for the journey.

DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
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 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
CEPI-001 / Continued

E. Opening Meeting

The inspection opening meeting shall be conducted by CEPI team members and appropriate
representatives of the inspected facility. The facility representatives shall include Saudi Aramco’s
foreman, and the rig contractor’s tool pusher, safety officer and medic. The purpose of this meeting is
to explain how the inspection will be conducted and how the inspection non-compliance items will be
reported. Attendance will be documented on the inspection checklist.

F. Conducting the Inspection

After the opening meeting, the E&OHU inspector will begin questioning the facility representative
using the prepared checklists. The inspector is not limited to the questions on the checklists and is
free to ask as many questions as necessary to verify compliance with the environmental and health
regulations and standards. Details of discrepancies or non-compliances will be written down as notes

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during the inspection. When the checklist items have been completed, the CEPI team shall meet and
discuss their potential non-compliance items and obtain additional clarification where required.

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G. Closing Meeting
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A draft list of potential non-compliance items and observations shall be presented to representatives
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of the inspected facility in a brief post-inspection closing meeting. The discussion will generally be
limited to the presentation of findings and the clarification of any misunderstandings.
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H. Final CEPI Report

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Non-compliance items will be reported in the final CEPI report. A priority rating will be assigned to
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each non-compliance item in order to identify the time allowed for each item to be resolved.
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I. CEPI Reporting Process

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E&OHU supervisor shall approve and send the CEPI report as per the following structure:
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1) For Drilling operations (drilling rigs):

a. Rig Superintendent.

b. Department Manager.

c. Department’s EC.

d. E&OHU EC.

e. DOE&CD Division Head.

DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
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This is an "UNCONTROLLED COPY" printed for reference only
 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
CEPI-001 / Continued

2) For Services:

a. Division Head (superintendent).

b. Department Manager.

c. Department’s EC.

d. E&OHU EC.

e. DOE&CD Division Head.

3) For Special Services Unit:

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a. Unit Supervisor.

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b. Drilling GM.

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c. E&OHU EC. P L
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d. DOE&CD Division Head.
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J. Corrective and Preventive Actions

The proponent department shall respond to the CEPI report non-compliance items through the HSE
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automated inspection system by submitting the corrective and preventive actions taken to close the
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items.
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The proponent must complete this before the expected completion date indicated on the CEPI report.
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K. Follow Up
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E&OHU shall notify the proponent department through the HSE automated inspection system when
the expected completion date is near. If the due date has passed and there is no response received,
a follow up email will be generated automatically and sent to the responsible persons as per reporting
structure in (5.I). If there is no response within seven days, E&OHU shall report the case to DOE&CD
division head.

L. Tracking Open Findings

A matrix will be maintained on the shared DOE&CD website by the E&OHU compliance group to
track the CEPI program. It includes inspection details, reporting, and open/closed findings.

DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
Revision(s) identified by a Vertical Bar in the Right Margin Page 5 of 7
This is an "UNCONTROLLED COPY" printed for reference only
 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
CEPI-001 / Continued

6. Responsibilities

A. DOE&CD Division Head

Responsible for reviewing this procedure.

B. E&OHU Supervisor

Responsible for final review and approval of the CEPI report, selecting the qualified environmental
coordinator to perform the inspection, and assigning emergency and priority inspections.

C. E&OHU Compliance Group leader

Responsible for: inspection notifications; preparing, maintaining and updating the inspection

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checklists (EPA, CEHA, etc.); maintaining and updating the CEPI Tracking Matrix; preparing the
inspection plan; and reviewing the draft CEPI reports.

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D. E&OHU Environmental Coordinators
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Responsible for assisting with inspection notifications, inspection preparation, conducting inspections,
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and writing the draft CEPI reports.
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E. Proponent Department

Responsible for providing any information requested by the CEPI Team in sufficient time, and to close
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the open findings as per the priority given in the Final CEPI Report.
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DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
Revision(s) identified by a Vertical Bar in the Right Margin Page 6 of 7
This is an "UNCONTROLLED COPY" printed for reference only
 Comprehensive Environmental Performance Inspection
DOE&CD-E&OHU-CEPI-001
Revision Summary

Approvals
Rev No. Date Revision Summary
Custodian Approval
Originator Review Authority
00 Jan 2013 Original Release as Internal AAS, SSG RGW ASA & ASG
DOE&CD / E&OHU procedure & JBM

NOTE: Signed Original(s) are maintained within DOE&CD.

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DOE&CD-E&OHU-CEPI-001-R0 / Created: 01/13 / Last Review: 01/13/ Next Review: 01/17

Owner: Division Head / DOE&CD
Revision(s) identified by a Vertical Bar in the Right Margin Page 7 of 7
This is an "UNCONTROLLED COPY" printed for reference only